Part 3 of the Home Office guidance for Worker and Temporary Worker sponsors was republished on 28 August 2026. The update did not introduce a new set of eVisa record-keeping duties. The main eVisa-specific record changes had already appeared in Appendix D on 3 August 2026, reflecting the move away from physical immigration documents.
The August Part 3 update instead covers changes including the phasing out of Level 2 SMS users, an extension of the right-to-work scheme to certain other working arrangements from 1 October 2026 and mandatory multi-factor authentication for SMS users from 3 September 2026. Home Office sponsor duties and compliance guidance
For employers, the practical message is still important: sponsored-worker records need to reflect an immigration system in which eVisas, online right-to-work checks and digital evidence have largely replaced BRPs and visa vignettes.
Why the timing matters
Biometric residence permits are no longer issued and are no longer valid as evidence of immigration status. Visa vignettes also stopped being issued to all applicants granted entry clearance from 1 July 2026. Sponsored workers granted status through the current system will normally evidence their immigration status digitally.
An expired BRP does not itself prove a current right to work. Some former BRP holders can continue using their card details for a limited period to access their UKVI account or generate a share code, including transitional arrangements running up to 31 December 2026 in some cases. The employer must still complete the prescribed right-to-work check.
For an eVisa holder, that will normally mean using the Home Office online “Check a job applicant’s right to work” service with the worker’s right-to-work share code. If the online service cannot be used in the relevant circumstances, other prescribed routes, including the Employer Checking Service, may apply.
What the sponsor guidance actually requires
| Duty | What it requires | eVisa-specific point |
|---|---|---|
| Record keeping | Keep prescribed evidence of right-to-work checks, recruitment, salary, role eligibility and other sponsored-worker records | Save evidence of the completed online right-to-work check, not simply the worker’s share code or a screenshot of their own eVisa |
| Reporting | Report specified worker changes, generally within 10 working days; most organisational changes within 20 working days | Changes affecting the sponsored employment or sponsorship position still need to be identified and reported through the appropriate SMS process |
| Compliance visits | Cooperate with announced or unannounced Home Office compliance checks | Digital records must be available when requested; where records are not immediately available, compliance officers will normally allow a reasonable period for production |
The latest Part 3 guidance confirms that worker-related changes are generally reportable within 10 working days, while most changes to the sponsoring organisation have a 20-working-day deadline.
The eVisa record-keeping detail employers miss
A share code and evidence of a completed right-to-work check are not the same thing.
Right-to-work share codes are normally valid for 90 days. The employer uses the code and the worker’s date of birth to access the Home Office employer checking service. The important record is then the resulting profile page confirming the person’s right to work, including their photograph and the date the check was conducted. Employers can save that page as a PDF or HTML file or retain a printed copy.
For someone with time-limited permission, the next follow-up check is determined by when their permission to work expires, not by when their original share code expires. A further check should be completed on or before the end of that permission if employment will continue.
For right-to-work purposes, evidence generally has to be retained for the duration of employment and for two years afterwards. Sponsor records under Appendix D have a different general retention rule: unless otherwise stated, they are retained during sponsorship until the earlier of one year after sponsorship ends or the date a compliance officer examines and approves them.
That distinction is worth building into your HR system rather than relying on one blanket deletion date.
A quick self-audit
Pick three sponsored workers and see whether you can produce their complete right-to-work evidence quickly.
You should be able to identify the completed Home Office online check, the date on which it was performed, the immigration permission shown, any restrictions on the work permitted and, where permission is time-limited, when a follow-up check will be required.
Do not rely on a screenshot supplied by the worker from their own UKVI account. The employer must use the prescribed employer-facing right-to-work service where an online check is required.
Home Office compliance officers can conduct announced or unannounced visits. They can request documents relating to sponsored workers and the organisation. Current compliance guidance recognises that documents may not always be immediately available and says a reasonable production period should be allowed, normally around 48 hours in many circumstances.
This mirrors the wider audit discipline in our note on sponsor licence compliance, and the same logic applies to salary, occupation and sponsorship records covered in our guide to Certificates of Sponsorship.
What non-compliance actually costs
A B-rating is one possible response to relatively minor sponsor-duty breaches that the Home Office believes can be corrected. It is not necessarily the first consequence in every case. More serious or systematic failures can lead directly to suspension or revocation.
A sponsor downgraded to a B-rating must follow an action plan, currently costing £1,579, and cannot normally sponsor new workers until its A-rating is restored. Action plans run for a fixed three-month period. Failure to make the required improvements can result in revocation.
Revocation is significantly more serious. There is no statutory right of appeal against a sponsor-licence revocation, and the organisation cannot normally apply for another licence for at least 12 months. Where an existing sponsored worker was not involved in the conduct that caused the revocation, their permission will normally be shortened so that they have 60 calendar days remaining, or left unchanged if less than 60 days already remain.
That can affect workers approaching Indefinite Leave to Remain if they need to secure new sponsorship or another immigration route. Longer-term plans for British citizenship by naturalisation can also be affected indirectly if a disruption changes the person’s immigration or residence history.
Where this sits alongside your other duties
The digital-status changes are only one part of sponsor compliance.
In March 2026, the Home Office introduced the defined concept of an “eligible role” across the sponsor guidance. Appendix D also introduced a record-keeping duty requiring sponsors to retain evidence that sponsored workers have been made aware of their employment rights in the UK.
If your workforce includes recent graduates, our piece on switching from a Graduate visa to Skilled Worker covers the sponsorship paperwork involved. Right-to-work evidence, salary records, role information and sponsorship records should all form part of the same controlled HR process.
Book a record-keeping review before a visit finds the gap
A sponsor should be able to produce accurate records without reconstructing them after the Home Office asks. Review how your HR system records online right-to-work checks, visa expiry dates, follow-up checks, salary evidence, role information and reportable changes before a compliance visit tests the process.
Speak to our team in Bromley about reviewing your eVisa and sponsor records, or see our full range of UK immigration services for individuals and employers.